The Centers for Medicare & Medicaid Services (CMS) recently issued its Proposed Rule for 2019 under the Quality Payment Program. In addition to changes within each performance measure category, there are some proposed high-level changes that practices should take notice.
The changes under the 2019 Proposed Rule include:
Adding new Eligible Clinicians who must report. In addition to physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists, these are the clinicians proposed for 2019: physical therapists, occupational therapists, clinical social workers and clinical psychologists. CMS also is considering adding qualified speech language pathologists, audiologists, certified nurse midwives and others.
CMS has added a third criterion for determining eligibility status. In addition to clinicians having less than $90,000 in Part B charges or clinicians with less than 200 beneficiaries, the third exclusion factor is those clinicians with less than 200 covered professional services under the Physician Fee Schedule. Clinicians who participate in an Advanced APM will continue to be excluded.
Below is a table that illustrates the opt-in options for 2019 based on beneficiaries, dollars and covered professional services. Practices must be sure to include the list of new eligible clinicians when considering if they meet or exceed one or two of the criterion. Practices must also understand that once you opt-in to MIPS participation for a performance year you cannot opt-out. Opting in will make your clinicians eligible to receive positive payment adjustments under MIPS.
Performance Threshold Points:
The minimum number of points needed to avoid a downward adjustment in reimbursement moves from 15 points to 30 points in 2019.
Categories are reweighted in 2019 to include Quality at 45 percent, Promoting Interoperability at 25 percent, Cost at 15 percent and Improvement Activities at 15 percent.
Payment adjustment for the performance year of 2017 (payment year of 2019) are +/-4 percent; in the 2018 performance year (payment year of 2020) it is +/- 5 percent; in the 2019 performance year (payment year of 2021), the payment adjustment increases to +/-7 percent.
The comment period for the 2019 Proposed Rule closed on Sept. 10. We expect the Final Rule on the proposals above to be released in November.
If you have additional questions about the 2019 Proposed Rule or questions about MIPS reporting, contact the Quality Reporting Engagement Group at QREG@intrinsiq.com